International

Our clients appreciate our service.

Our partners of the firm are qualified with more than 15 years of international experience in multinational firms as experts and tax advisor in international tax law.
We maintain partnerships in all major cities of Germany and have close links with tax an law firms in Europe, the USA and Asia.

International tax planning

In times of globalisation and national mobility, one of our focuses is outbound advice for our domestic clients and investments to Germany by non-residents.
In addition to the taxable presence of permanent establishment or agent permanent establishment, issues of avoidance of double taxation under foreign tax law
and double tax treaties and the multiple compliance obligations play a crucial role for the principal place of management. Not to be underestimated,
there are also pitfalls in VAT-exempt EU or export supplies. In addition, the acquisition of companies or parts of companies, including tax-optimized financing structures,
is often the first step in the transition to foreign markets. Our partners within the firm have many years of international expertise in the practical implementation
of tailor-made structures and the avoidance of cross-border tax pitfalls on the other hand.

Real estate structuring

Besides legal specifics, the acquisition of domestic real property is also tax-wise connected with pitfalls and risks, especially in the use of tax havens.
Particularly real-estate owning companies have to consider tax optimization measures in terms of real estate transfer taxes by choosing a legal form.
Further tax risks entail issues of transfer of going concerns for VAT purposes. Our partners as tax advisors have over ten years of international experience and
support you in structuring the acquisition of real estate, the tax clauses and tax-optimized sales.

Real estate transfer tax planning

Tax-neutral transmission in the group

Low-tax transfers of real estate companies

RETT-Blocker-structures

Monitoring of vesting periods

Restructuring

Legal form of real estate companies

Restructuring of real estate portfolios

Tax deferral structures

Structures for avoiding corporate splits

Avoidance of trade tax burden

Shielding effect of commercial property trading

Structures for an extended trade tax reduction

VAT exposures

Separation of private properties from operating activities

Tax clauses in SPA/APA

Tax monitoring of investments

International VAT

Despite European harmonization of VAT, divergences in cross-border supply chains, exports or the reverse charge procedure exist, due to local laws.
We support you, in the field of international tax law, in respect of the tax registration of foreign companies in Germany, ongoing VAT compliance and
representation before tax authorities. Our partners are proven experts in international VAT and members of corresponding national VAT advisory boards.

Internal processes

VAT-check of internal processes

Electronic invoicing business

In-house VAT manuals for typical business transactions

Tax paper on VAT issues

Monthly VAT filings and cross-border declarations

Filings abroad

Assembly facilities

VAT refund procedure

Tax registration obligations

Real estate

Optimization of input tax keys

VAT clauses in purchase agreements

Tax controversies

Representation in special VAT audits, unannounced audits and tax field audits

Legal objections

Binding rulings

Fiscal court proceedings

Customs inspections

Supply chains

Chain and triangular transactions

Foreign warehouse

Import VAT and customs declaration

Secondment of employees

The temporal secondment of employees in inbound and outbound scenarios has become part of common practice, particularly of temporary project assignments,
in companies. We support both companies in fulfilling their tax obligations and income tax issues of seconded employees both domestically and at foreign locations.

Employer advice

Wage tax planning

Tax calculation for salary fixing domestically and abroad

Tax planning regarding secondment agreements

Charge back agreements and transfer pricing

Avoidance of permanent

Tax optimization on remuneration

Advice on social security treaties

Audits in international assignments

Tax-motivated severance payments

Employee advice

Arrival-Interviews

Domestic tax declaration

Coordination with foreign tax colleagues in the country of residence

Tax structuring due to double tax treaties

Avoidance of exit taxation

Employment premium

Stock option modells

M&A Transactions

In times of globalisation and national mobility, one of our focuses is outbound advice for our domestic clients and inbound investments to Germany by non-residents.
In addition to the taxable presence of permanent establishment or agent permanent establishment, issues of avoidance of multiple taxation and international agreements
by the double taxation agreement, as well as the multiple compliance obligations play a crucial role for the selection of the formation.
Our partners have decades of experience in the tax support of domestic and cross-border corporate transactions of any company size. A good tax advice on the acquisition process can both shorten the duration
of the acquisition transaction as lead to a tax-optimized acquisition structure. We support our clients with due diligence, tax-related agreements and in the negotiations with the parties involved.

M & A transaction

Analysis of alternative options for potential sales

Due Diligence

Sale of companies or assets

Tax valuation of companies

SPA, APA (including tax clauses)

Tax planning for a transaction structure

Corporate structures

Choice of legal form

Tax function and risk analysis

Tax group structures

Company leasing

Transformation into another legal form

Capital and organizational restructuring

Loss utilisation strategies

Company succession

Tax-optimized business and assets structures

Anticipated succession

Separation of ownership and management position

Business integration

Foundations and administration of estates

Inheritance tax valuation of companies

Structuring of tax benefits

Pool agreements

Compliance

We support our clients in their annual local tax filing obligations as well as the preparation of financial statements in English.
Next to VAT declarations this includes all declarations for corporate income tax purposes.